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Social Security Disability Adjudication Social Security Disability Adjudication

Social Security Disability Adjudication - PowerPoint Presentation

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Social Security Disability Adjudication - PPT Presentation

How the Social Security Administration Has Used Data Analysis to Improve the Disability Program A Brief Overview of the Disability Process 2 Disability is the gateway to retirement from the workforce for many unfortunate people ID: 499884

data disability security adjudication disability data adjudication security social decisions training cases appeals hearing federal council court acus decision case ssa

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Slide1

Social Security Disability Adjudication

How the Social Security Administration Has Used Data Analysis to Improve the Disability ProgramSlide2

A Brief Overview of the Disability Process

2

Disability is the gateway to retirement from the workforce for many unfortunate people

There are up to four levels of administrative review. Claims are typically filed in local field offices or online

Disability claims are considered at the initial and reconsideration stages by 54 State agencies known as the Disability Determination Services (DDS)

Hearings and appeals are handled by federal employees in SSA’s Office of Disability Adjudication and ReviewSlide3

Appeals Council Review

3

The Appeals Council processes appeals of hearing decisions and dismissals

The Appeals Council also has authority to randomly or selectively sample hearing decisions and dismissalsSlide4

Civil Actions

4

The Appeals Council’s action is the last step of the administrative review process unless the Council issues an order of remand

An individual may file a civil action in federal court to seek judicial review of SSA’s final decision, usually an ALJ’s decision

The Appeals Council is responsible for

producing

a certified copy of the administrative recordSlide5

Comparative Data FY 2014

5Slide6

Social Security Disability Adjudication

Defining and Improving Quality in Disability Adjudication Slide7

Improving the Quality of Service Delivery

We

continuously look for ways to improve the quality and consistency of our case adjudication, while reducing processing times and the cost of the services we provide

Our goal has always been to deliver fair and accurate decisions as quickly as we can

In the last

7 - 10

years, we

have moved

toward electronic processing of

claims, opening

up new opportunities to improve our business processes and service

deliverySlide8

A Measurable Definition of Quality for Decisions

We developed a

clear, understandable, and

measurable

definition of quality from a customer standpoint

A Quality Decision Is…

factually accurate,

procedurally adequate,

policy compliant

timely issued, and

supported by the evidence

8Slide9

Mapping the Adjudication Process

We built a decision-tree mapping the regulatory requirements regarding the issues that need to be addressed in each case

We determined the

pathing

to each of the 2000 possible outcomes in disability cases

We developed analytical tools to guide adjudicators through appropriate pathing

We developed analytical tools to deconstruct and capture data about the decisions that are madeSlide10

Mapping the Service Delivery Requirements

10Slide11

Policy Compliant Decisional Tools

We developed two types of tools to guide adjudicators through policy compliant

pathing

:

The electronic cases analysis tool (

eCAT

) is used at the initial and reconsideration levels to guide adjudicators in reaching appropriate conclusions

The electronic Bench Book (

eBB

) is used at the hearing level in a similar manner

The Appeals Council Analysis Tool is used at the Council to guide reviewers in pinpointing errors in hearing level adjudicationSlide12

Gathering Actionable Data

Slide13

Gathering Actionable DataSlide14

Social Security Disability Adjudication

Analyzing, Visualizing and Utilizing

Data

to Improve PerformanceSlide15

Analyzing and Visualizing the Data

The capture of structured data in the analysis tools provided a wealth of information that we can mine to improve the quality and consistency of disability adjudication.

The Agency has more than 14 petabytes of data housed in more than 200 separate databases

We use a variety techniques to mine the data, including:

Regression analysis

Clustering analysis

Pattern mining

Computational linguistics

We

also employ a variety of data visualization techniques

Slide16

The Focused Review Process

Typically we identify outlier behaviors in the data and address the most significant ones

first

Outliers might be doing things better or worse than other

employees

We conduct focused reviews of outliers to learn what may account for their differences in service delivery

We conduct focused reviews of issues or of the work of individuals Slide17

Common Findings of Focused Reviews

Common findings

of

focused reviews

of

hearing decisions include:

Inadequate development of the record

Lack of supporting rationale

RFC problems/ opinions not properly evaluated

Lack of adherence to business processes

We had seen these problems for years and remands were not particularly effective. We wanted to know:

What is causing these errors and what can we do to change behaviors to reduce these errors?

17Slide18

Improving Heuristics in Case Adjudication

What seemed clear was that some employees had developed heuristics that do not always match policy requirements

Heuristics are typically used in problem solving, particularly complex problem solving

Heuristics are a mental framework that people have relied on in the past – they allow people to simplify consideration of the issues

Thus, although employees generally try to do the right thing, they did not always have a clear understanding of what that is

18Slide19

Improving Heuristics in Case Adjudication

We take the view that generally employees are self-motivated and will seek out responsibility in achieving objectives to which they are committed

Thus we needed to consider why people were developing heuristic models that were inconsistent with the policiesSlide20

Improving Heuristics In Case Adjudication

Noble Laureate and Professor Daniel

Kahneman

suggests these requirements for the development of proper heuristics:

A stable world in which problems are solved

Immersion and experience in that world

Immediate and recurring feedback regarding the heuristics developed

20Slide21

Social Security Disability Adjudication

Pushing Feedback and Training to Adjudicators - How MI Doing - Slide22

Providing Feedback - Training Design

We re-designed our training to focus on the end of training and what an employee had to be able to do (skills) beginning on day one

By changing our focus to the end result, we created a curriculum designed to be inter-active & skill based

We

created new training materials that blend research, analysis and casework into a comprehensive interactive

experience

In 2011, and again in 2015, the Council won the prestigious Deming Award from the Graduate School USA for outstanding federal government trainingSlide23

Improving Heuristics in Case

Adjudication

We also developed a tool called “How MI Doing” to provide direct feedback and push training to ALJs when in-person training is not feasible

How MI Doing includes:

Comparative information regarding dispositions, timeliness, productivity

Comparative information about the quality of work produced

Multi-level training modules tied directly to identified errors in casework (reasons for remand)

23Slide24

This next view shows the agree rates for decisions (blue) and dismissals (orange) by region. Click on a column to drill down to the next level.

24Slide25

If you want training information pertaining to a remand reason, click on the reason.

Remand Reason TrainingSlide26

How MI Doing – Desk Guides

26

The Tier 1 document always contains Appeals Council feedback, SSA policy

, why this issue matters, situations to watch out for, and what do to resolve the issue.Slide27

How MI Doing – Desk Guides

27Slide28

Social Security Disability Adjudication

Results of Feedback and Training EffortsSlide29

Change in High/Low Allowance Rate ALJs

Slide30

Changes in Remand & Appeal Rates

 

2009

2010

2011

2012

2013

2014

Appeals to AC as

a Ratio

of Appealable Cases

36.67%

39.49%

45.17%

38.85%

37.59%

40.76%

AC Remands as

a Percentage

of All Dispositions

22.12%

21.77%

21.19%

18.62%

17.11%

14.34%

New Court Cases Processed at AC

as

a Ratio

of Appealable

AC Dispositions

19.03%

16.23%

15.07%

12.99%

13.67%

14.44%

Federal Court Remands as a Ratio of Court Dispositions

47.5%

46.9%

46.12%

44.8%

42.35%

42.57%

30Slide31

Social Security Disability Adjudication

Improving Operational EfficiencySlide32

Differential Case Management

Adjudicators handle hundreds of claims per year, but there are about 2000 different types of decisions that can be issued in disability claims

We used k-means clustering techniques to do this, running quadrillions of calculations using hundreds of case characteristics and dozens of pivotal issues to sort cases by similarities

Sorting

and assigning similar cases improves the speed of processing, as adjudicators can apply the same policy compliant

pathing

to a series of similar

cases

Preliminary data shows errors and returns for pre-decisional rework have been cut in halfSlide33
Slide34

How OAO Improved Timeliness – Differential Case ProcessingSlide35

Growth in RRs, Dispositions vs. Staff Growth

FY 2009-FY 2013Slide36

Results – Increased DispositionsSlide37

Social Security Disability Adjudication

Computational LinguisticsSlide38

New Technologies

Optical Character Recognition

Converts images of text into editable/searchable text.

Natural Language Processing

A field of computer science focused on creating systems that can ‘understand’ the meaning of human (natural) language, such as text.

Machine Learning

Systems that can study a set of data and

independently

find commonalities in the data or make ‘informed choices’ in the face of new data.

5. The

claimant has the residual

functional capacity to perform

sedentary

work

except: he can occasionally

stoop and

kneel but must never crawl

.

residual

functional capacity

to perform

sedentary

he

can

occasionally

stoop

and

kneel

must

never

crawl

Example

: A hearing decision, including its RFC, are converted from an image into text:

.. The computer analyzes the text’s meaning - dividing sentences, forming associations, etc..

… finally, the computer outputs what it’s learned as data we can use, such as Excel data.Slide39

Natural Language Processing Algorithms: An Example of These New Technologies In Action

Feature 1: Extracts New Data

Our Natural Language Process algorithms extract a range of previously unavailable/incomplete data from the text of hearing decisions. Some highlights:

Data Item

SSA

Data Now

Our NLP

Step 3 Listing Numbers Met/Equaled

None

Step 5 Medical-Vocational

Rules

None

Residual Functional Capacity

Limitations

(‘lift 20 pounds total’; ‘no stooping’, etc.)

None

Source Names Noted

by the Adjudicator

(

Robert Stevens, M.D.

,

opined

…’)

None

Step

2 Severe/Non-Severe Impairments

Limited (Max: 2)

(All)

An example: Our natural language processing captured ~284 cases where fibromyalgia was a severe MDI in the decision text but that information was not captured by CPMS:Slide40

The NLP Algorithms: An Example of These New Technologies In Action

Feature 2: Real-Time Hearing Decision Quality Checks

Our Natural Language Processing algorithms can automatically detect a variety of errors/deficiencies present in hearing decisions. This data can be used to alert decision writers to the errors in real-time, enabling them to correct them

before

decisions are issued:

Example of what an alert could look like:Slide41

Social Security Disability Adjudication

Improving Policies and ProceduresSlide42

CLUSTERING ANALYSIS HELPED VISUALIZE THE INCONNECTIVITY OF PIVOTAL POLICY ISSUESSlide43

Why We Don’t Change Our Policies More Frequently

Our current practice is to mobilize and analyze data about a problem, determine if we can address it with training, and then progress through changes in sub-regulatory guidance, before moving on to regulatory or legislative proposals

We publish changes to HALLEX and POMS, the operational instructions for disability adjudicators on an almost daily basis

Multiple Social Security Rulings are issued annually

Other types of changes require more extensive

consideration by people external to SSASlide44

ACUS Projects

Treating Source Rule and Role of the Appeals Council

Duty of Candor and Submission of All Evidence

Closing the Record at the Hearing Level

Symptom Evaluation

Federal

Court Variances

ACUS studied the following:

The impact of SSA’s treating physician rules on the role of courts in reviewing our decisions and consider measures that SSA could take to reduce the number of cases remanded to it by courts; and

The role of the Appeals Council in reviewing cases to reduce any observed variances.

ACUS studied the following:

The Act, any amendments to the Act, and SSA’s current regulations regarding the duty of candor and submission of all evidence in disability claims; and

The requirements from other administrative tribunals as well as the Federal Rules of Evidence, Federal Rules of Civil Procedure, and other authority regarding the duty of candor and the submission of evidence.

ACUS studied the following:

SSA’s current regulations, past regulatory initiatives, relating to closure of the record after ALJs issue decisions;

The impact of SSA’s current pilot program in the Boston region that requires closure of the record after ALJs issue decisions with one exception; and

Any other possible alternatives and exceptions to a closed record at the hearings level.

ACUS is studying the following:

The Social Security

Act, SSA’s current regulations, and SSA’s sub-regulatory policy and development and documentation practices regarding how SSA adjudicators at all levels evaluate claimants’ symptoms, including pain, in the adjudication of social security disability claims.

ACUS is studying the following:

ACUS will survey and analyze federal court interpretations and applications of SSA’s rules and regulations. ACUS also will note patterns that show consistencies or inconsistencies in these interpretations or applications by specific federal courts, as well as varied judicial practices and procedures in federal cases involving social security disability insurance and supplemental

security income.Slide45

Social Security Disability Adjudication

Issues Addressed by District Courts in the 9

th

CircuitSlide46

2014 New Court Cases and Court Remands

Slide47

Evaluation of Subjective Complaints

Slide48

Evaluation of Medical Opinion Evidence and Residual Functional Capacity

Slide49

“Credit As True” Doctrine

In a series of cases dating back to 1988, the 9

th

Circuit has indicated it will credit as true both medical opinions from treating sources and testimony of witnesses that has been either improperly rejected or not adequately addressed in the hearing decision

The 9

th

Circuit requires that the agency must provide “clear and convincing reasons” when rejecting claimant testimony or treating source opinionsSlide50

“Credit As True” and the Evaluation of Treating Source Opinion Evidence

A 2013 ACUS

sponsored research report

noted

that Federal court preoccupation with the weight that ALJs assign to treating sources often has diverted court focus from the pivotal question of a claimant’s disability

(

see “

Assessing

the Efficacy of the Treating Physician

Rule”

– available at

www.acus.gov

)

The agency is actively engaged in the process of drafting new regulations regarding the evaluation of medical opinion evidence Slide51

Social Security Disability Adjudication

How the Social Security Administration Has Used Data Analysis to Improve the Disability Program